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This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Responses to Sanford Cohen & Associates 

Review of Battelle -TBD-6000 

Appendix BB

(General Steel Industries, Rev. 1)

Response Paper 

National Institute for Occupational Safety and Health

Division of Compensation Analysis and Support

January 8, 2015

By David Allen

Reviewed by James W. Neton, Ph.D., CHP
Response Paper Review of Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 1) January 8, 2014

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This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

GENERAL

This document contains responses to the findings in Sanford Cohen & Associates’ December 10, 

2014, memo that provided review comments on NIOSH’s revision 1 to Appendix BB of TBD6000, General Steel Industries. The memo also contains a number of editorial comments and 

suggestions that were not summarized in the findings and are not addressed in this document. 

DCAS intends to address each editorial comment and suggestion when Appendix BB is revised 

to incorporate our responses the findings.

FINDING #1. Neutron Dose Rates

SC&A commented that the effective neutron dose was calculated while OCAS-IG-001 does not 

contain dose conversion factors for this dose.

NIOSH Response: The values in Appendix BB match the numbers agreed to during an exchange 

of files between SC&A and NIOSH prior to the drafting of the appendix revision. Both SC&A 

and DCAS neglected to realize at the time that calculating effective dose was not appropriate. 

DCAS will revise the calculations to use either ambient dose equivalent or deep dose equivalent 

conversions.

FINDING #2. Beta Skin Dose

SC&A commented that their calculation of beta dose is different than DCAS. 

NIOSH Response: DCAS and SC&A exchanged files and reconciled differences late in 2013

prior to the drafting of the revision to Appendix BB. Appendix BB contains those values. Even 

though not included in the text of the summary for this finding, SC&A acknowledges in the body 

of this memo that they originally neglected to account for the one meter beta dose so it was 

calculated and added to the total dose as part of their review. This explains the difference 

between the Appendix BB and SC&A’s recalculated values.

DCAS intends to correct this in the next revision to Appendix BB. However, the original 

calculations assumed the steel was irradiated for 30 continuous hours. DCAS intends to adjust 

the initial dose rate to account for the intermittent irradiation as described in a white paper that 

recalculates the layout man’s beta dose. DCAS also intends to assume the steel was irradiated 

long enough to reach an equilibrium activity.
Response Paper Review of Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 1) January 8, 2014

Page 3 of 5

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

FINDING #3. No Dedicated Radiography Facility in No. 6 Building Prior to 1955

SC&A indicated there is evidence that the radiography facility in the 6 building may not have 

been constructed until 1955. This would affect the basis for the mode dose of the triangular 

distribution for the radium radiographer dose through 1955. 

NIOSH Response: DCAS agrees with SC&A however, a slight correction is necessary. The 

calculations used by SC&A in their review report assumed the 15 seconds to place or retrieve the 

source was part of the exposure time. In the previous calculation, the time placing and retrieving 

the source was in additional to the exposure time. In keeping with that interpretation, the new 

calculated dose would be 11.34 R/y rather than 11.28 R/y. DCAS intends to use the 11.34 value.

FINDING #4. Maximum of Triangular Distribution of Photon Exposures for 1961 Should 

be 12 R/y

SC&A commented that the relevant revision to 10CFR20 was effective 1/1/1961 so the upper 

limit to the radium radiographer dose should be 12 R/y in 1961 not 15 R/y.

NIOSH Response: DCAS agrees. The error will be corrected in the next revision to Appendix 

BB.

FINDING #5. Combined Exposures to 226Ra and Betatron Operations during 1952-1962

SC&A commented that since radium radiography only occurred 30% of the time, the 

radiographers should be assigned betatron operator dose the remaining 70% of the time.

NIOSH Response: This is clearly a change from what had already been discussed and resolved. 

The 30% value that SC&A cites is actually the amount of time the radium source is exposed. 

The process of performing radiography requires a number of other steps, including marking the 

casting, moving the source to and from the location, placing the film, removing the film, 

developing the film, determining the duration of the shot, etc. 

In the betatron building, it was assumed it took 15 minutes between shots on the same casting. It 

was further assumed the castings were often marked up prior to entering the betatron building. 

That was the job of the layout man for large castings but there is no indication a separate person 

was used for the smaller castings that would be radiographed using radium or cobalt sources. 

Therefore, it would not be unreasonable to double the time between shots to 30 minutes. Ten 
Response Paper Review of Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 1) January 8, 2014

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This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

shots per shift times 30 minutes per shot equals 5 hours of work per shift. Adding the 2.4 hours 

of shooting time to that accounts for the majority of the shift.

FINDING #6. Beta Skin Dose to Layout Man

SC&A comments that the Appendix BB beta dose to the layout man is significantly lower than 

those calculated by SC&A

NIOSH Response: This dose requires detailed discussion and is therefore the subject of a 

separate white paper that will be issued at the same time as these responses.

FINDING #7. Uranium Inhalation from Metal Handling in 1966

SC&A points out the inhalation intake for the first six months of 1966 is half the value it should 

be. 

NIOSH Response: DCAS agrees. The intake was inadvertently averaged over the full year 

instead of 6 months. The error will be corrected in the next revision to Appendix BB.

FINDING #8. Ingestion Intakes Not Consistent with OCAS-TIB-009

SC&A points out that the ingestion intakes are significantly higher than they should be.

NIOSH Response: DCAS agrees. OCAS-TIB-009 is intended to apply to continuous operations 

and no adjustment was made for intermittent uranium work at GSI. DCAS agrees this would it 

would be more appropriate to use the average airborne activity for the year. However, DCAS 

suggests using the average annual airborne activity for the highest year, rather than changing the 

ingestion rate based on the amount of uranium work for a particular year. The ingestion rate is 

related to the surface contamination present and that value does not start at zero each year. Thus,

contamination from a previous year can affect the ingestion rate in a following year. Since the 

highest year ingestion rate would be the first years, DCAS intends to revise the appendix to use 

that ingestion rate (calculated in the SC&A memo and verified by DCAS) for all years. This 

would also be the ingestion rate for the first year of the residual period.

FINDING #9. Ingestion Intakes during Residual Period

SC&A points out the ingestion rate in the first year of the residual period is incorrect.
Response Paper Review of Battelle -TBD-6000 Appendix BB (General Steel Industries, Rev. 1) January 8, 2014

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This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response: DCAS agrees. The inhalation rate for the last operational year was 

inadvertently used as the ingestion rate for the first year of the residual period. Thus, the value 

should have been 15.44 dpm/day rather than the 15.88 dpm/day used in the Appendix. As stated 

in our response to Finding 8, DCAS intends to use the ingestion rate for the highest operational 

year for the beginning of the residual period in the next revision to Appendix BB.